25017 - Moser Baer PV

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Environmental & Social Review Summary

Project Number

25017

Company Name

Moser Baer Photovoltaic Limited

Date ESRS Disclosed

Nov 14, 2006

Country

India

Region

South Asia

Last Updated Date

Nov 30, 2016

Environmental Category

B - Limited

Status

Active

Previous Events

Approved : Mar 14, 2007
Signed : May 7, 2007
Invested : Dec 17, 2007

Sector

Electrical Machinery, Equipment and Components (Electric Lighting, Motors, Batteries, Insulated Wires and Cables, Fiber Optic Cable, Carbon and Graphite Products, etc.)

Industry

Manufacturing

Department

Regional Industry - MAS Asia & Pac

Project Description

Moser Baer India Limited (MBIL or the company), an existing IFC client is the third largest manufacturer of recordable optical storage media products (e.g. compact discs, DVDs) in the world. MBIL is undertaking a two year diversification program that involves setting up an export oriented solar photovoltaic (PV) cell and module manufacturing facility on the campus of its existing plant in the rapidly expanding New Okhla Industrial Development Area (NOIDA) industrial estate in the state of Uttar Pradesh (UP), some 27km from Delhi. The project will be implemented in two phases (with an installed capacity of 40 MW for each phase) through Moser Baer Photo Voltaic Limited (MBPV or the project company), a wholly owned subsidiary of the company that has been created for this purpose. The implementation of the second phase will be contingent on the successful launch and operational ramp-up of the first phase.

Overview of IFC's Scope of Review

This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The following potential environment, health and safety and social aspect of the project were analyzed:

- corporate environmental, social, and health and safety management systems;
- national and local government permitting requirements;
- labor and working conditions including occupational health and safety in construction and operation;
- site location and acquisition;
- source of power and energy, including fuel storage if applicable;
- air emissions during construction and operation;
- ambient air quality and noise impacts on nearby receptors during construction and operation;
- source and volumes of water consumed including efforts to minimize water use;
- recycling and treatment of process effluent and domestic waste water;
- hazardous materials management;
- minimization, recycling and disposal of solid and hazardous wastes; fire and life safety and emergency response;
- community engagement, health, safety and security; and
- corporate social responsibility efforts, including HIV/AIDS awareness.

The review of this project consisted of appraising technical, environmental and social information submitted by the project company. In addition, IFC met with the project team at Moser Baer’s corporate offices in Delhi.

E & S Project Categorization and Applicable Standard

- PS 1: Social and Environmental Assessment and Management Systems;
- PS 2: Labor and Working Conditions;
- PS 3: Pollution Prevention and Abatement; and
- PS 4: Community Health, Safety and Security.

The project appraisal also assessed the applicability of PS 5 Land Acquisition and Involuntary Resettlement and PS 6 Biodiversity Conservation and Sustainable Natural Resource Management. In regard to PS 5, the project site is part of the company’s existing CD/DVD production facilities located at 66, Udhyog Vihar in Greater Noida on the outskirts of the metropolitan Delhi area. As a result, development will not result in economic displacement. With respect to PS 6, there are no environmentally sensitive areas within or adjacent to the site.

The project will involve a small development in a peri-urban industrial area on 94 acres of land which are located in the same campus as the company’s existing CD/DVD production facilities. The key social, environmental, health and safety impacts associated with the project will include:

- emissions to air and water;
- management of hazardous materials and wastes;
- labor and working conditions, employee occupational health and safety and community health and safety during construction and operation.

Given that the proposed project location in a heavily modified area, adverse impacts on environmentally sensitive areas are not expected to occur. The nature of the company’s operations is such that it will be possible to readily design and implement engineering and management measures to mitigate any adverse impacts that result from the project. Moreover, in light of the fact that mitigation measures can readily be designed, adverse impacts are not expected to be diverse or irreversible and will be limited to project site, and no physical or economic displacement of communities occurred, the project has been classified as a Category B.

Environmental and Social Mitigation Measures

The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank/IFC environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow.

- PS1: Social and Environmental Assessment and Management Systems:

The proposed development does not fall under Schedule I of the Ministry of Environment and Forests (MoEF) Environmental Impact Notification Act, 1994. As a result, MBPV was not required to submit a Rapid Environmental Impact Assessment and Environmental Management Plan to MoEF to obtain Environmental Clearance for the development. MBPV has applied to MoEF for a No Objection Certificate (NOC) for the proposed PV plant and will forward a copy to IFC within 30 days of receipt of the NOC from MoEF. MBPV will adopt social and environmental management systems for the PV project that are in line with the Integrated Management System (IMS) in place at the company’s existing operations. The IMS includes quality management, environmental management and occupational health and safety management systems, which have been independently certified (by DNV) against ISO 9001, ISO 14001 and OHSAS 18801 criteria respectively. The company expected to be SA 8000 certified by December 2006. The same systems will be adopted, with appropriate modifications to take account for differing production considerations, at the PV plant. As has been done for the company’s existing business, the project company will ensure that an environment, social and health and safety department exists at both the plant and corporate level. ESH&S issues will be managed at the corporate level by a corporate level Environmental Manager, who will oversee a qualified and experienced ESH&S team of senior and junior engineers to monitor performance and ensure compliance with government and IFC requirements.

The project company has applied for all relevant national and local government permits, approvals and clearances, including Consent to Operate. Copies of approvals, permits and clearances not yet received by MBPV will be provided toIFC within 30 days of receipt by the project company, in accordance with the schedule outlined in the Action Plan attached to this document. IFC has made three previous investments in the company’s CD/DVD manufacturing business, the earliest of which was in 1996. The company has provided detailed, timely Annual Environmental and Social Monitoring Reports (AMRs) over this period, has maintained a strong record of compliance with both Indian and World Bank Group (WBG) environmental requirements, and has provided current copies of relevant permits and operating licenses to IFC on a regular basis.

- PS 2: Labor and Working Conditions:

Current employment in the company’s existing operations totals approximately 7000 at all three plants and in the company’s corporate office. Employment in the PV plant is expected to be approximately 200 workers over 3 shifts (+/-600 employees in total). IFC has had investments in MBIL since 1996, and the company has maintained exemplary, international best practice working conditions across all of its plants during this period. Comparable labor standards and working conditions will be established at the PV plant. MBPV will adopt a Human Resource policy, procedures and management system based on the one the company has in place for its existing operations. MBPV’s management team has confirmed that these policies and procedures will meet all PS2 requirements, including:

- establishing, maintaining and improving employee-management relations;
- allowing for the formation of worker’s organizations if these are desired by its employees;
- promoting fair treatment, non-discrimination and equal opportunity of workers;
- ensuring compliance with national labor and employment laws;
- promoting safe and healthy working conditions; and
- protecting and promoting the health of workers.

Existing HR policies and procedures are applicable to MBPV and will be submitted to IFC within an agreed timetable, prior to the plant becoming operational. The policy will establish a mechanism that allows employee grievances to be articulated and addressed, as well as procedures to cover retrenchment, as and when it may occur.

The company has stated that it views excellence in EHS issues as essential not only in reducing accident rates, environmental impact and occupational hazards, but also in promoting a culture that result in high staff productivity and low staff turnover.

The company has confirmed that it complies with all Indian labor regulations and standards including those relating to employment of minors. The minimum age of employees at the plants is 21 years of age. MBPV’s production machinery will meet international safety standards and be equipped with protective shatter-proof glass screens and interlock devices to prevent unsafe operation. Employees will be provided with personal protective equipment (PPE) appropriate to task requirements and trained in the proper use of this equipment. Noise levels in the plant will be within World Bank group limits with the exception of the diesel generating room. Employees will be provided with hearing protection as and when they need to enter this area. MBPV will provide training to all employees in accident prevention, fire control and emergency response. As at all MBIL facilities, company health officers will be on duty to assist in minor health problems and to provide training and advice on health related issues. All full-time employees will be covered under the company’s medical health insurance program. All MBIL plants are designed with strategically located fire exits and fire preventative and fire fighting measures in accordance with relevant laws and as advised by local fire authorities. Periodic training and drills are held. As it has done at its existing optical storage products plants, the company will engage a fire consultant to develop appropriate fire prevention, detection response and life safety systems at the proposed PV plant, and to develop an emergency fire evacuation plan. MBPV included specific occupational health and safety (OHS) provisions in the contracts it enters into with construction contractors to ensure that these contractors comply with both Government of India and WBG occupational health and safety requirements.

MBPV will include specific occupational health and safety (OHS) provisions in the contracts it enters into with construction contractors to ensure that these contractors comply with both Government of India and WBG occupational health and safety requirements. Environmental, health and safety during construction is will be jointly managed by the MBPV project team and the prime construction contractor, which has not yet been selected. As noted, MBPV will ensure that all construction contracts include specific environmental, health and safety (EHS) provisions, and that the prime contractor follows MBIL’s construction safety manual, which contains all relevant laws, regulations and standards of the Government of India as well as a number of international best practices and guidelines pertaining to construction activities. Implementation of these requirements will be the responsibility of concerned contractor and will be monitored by MBIL’s EHS Department.

- PS 3: Pollution Prevention and Abatement:

As noted, Moser Baer has maintained a strong record of environmental performance and management systems over the 10 years in which IFC has had investments in the company. The company has been designated as a “Green Partner” under a Sony program to encourage its suppliers to adopt environmental sound production processes. Under the program, Sony auditors visit suppliers to verify their environmental management policies and practices; only those suppliers who meet Sony''s standards receive the Green Partner designation. MBIL received the highest score of any supplier audited by Sony.

Pollution prevention and abatement at the PV plant will be based on the same approaches and systems and, in some case, will share infrastructure with the existing optical devises production facilities. On site power for MBPV’s operations will be provided by low sulphur diesel generating sets, which will be operated in compliance with Indian and World Bank Group limits in relation to air emissions. The existing IFC investment is in compliance with WBG air emission standards and similar generator sets will be used for the new PV plant. No impacts on ambient air quality or ambient noise levels are expected to result from Project operations. Fuel storage areas are equipped with secondary containment structures. The company has adopted a corporate energy saving program, wherein employees are encouraged to suggest energy efficiency measures and, if viable, these are adopted throughout the facility. These efforts have helped MB lower its energy consumed per ton of product over the last several years. Water will be drawn from on-site boreholes for which the company has permission from the relevant authorities. As with the company’s existing plants, relatively small quantities of water will be used for cooling, boiler operations, cleaning, canteen and ablution facilities. MBPV estimates that its daily water requirements will be approximately 130 kiloliters/day. The company has in place an ongoing program to minimize water use and encourage recycling throughout its operations, and was the first company in the area to install rainwater harvesting facilities.

MBPV intends to install an effluent treatment plant (ETP) that utilizes best practice technology to treat production wastewater, and a sewage treatment plant (STP) for domestic effluent that will meet Pollution Control Board and WBG limits. Liquid effluent from the entire plant will be collected in a central pond and transferred to the ETP for treatment. Treated water will be recycled for both process and irrigation purposes. Sludge from the ETP will be disposed of to authorized vendor in cake form.

The production process will not generate any hazardous wastes. The only hazardous wastes produced by MBPV’s operations will be used oil from machinery and fuel oil sludge from gensets, which will be sold to authorized vendors in accordance with provisions of the Hazardous Waste (Management and Handling) Rules (1989, 2000). Environmental, health and safety during construction is will be jointly managed by the MBPV project team and the prime construction contractor, which has not yet been selected. As noted, MBPV will ensure that all construction contracts include specific environmental, health and safety (EHS) provisions, and that the prime contractor produces a detailed EHS manual addressing all construction site activities, consistent with IFC guidelines and all relevant Government requirements. A copy of the EHS manual has been provided to IFC.

- PS 4: Community Health, Safety and Security:

MBIL has a demonstrated history of community engagement, health, safety and security, as well as a commitment to corporate social responsibility (CSR) efforts. The company has set up a separate CSR department at the corporate level and has developed a comprehensive, written policy document on CSR which considers CSR issues and practices both internally and externally. Internally, CSR issues and practices are being addressed through policy formulation, compliance with relevant national and local laws and international best requirements. MBIL has developed an on-site and off-site emergency response plan, which has been submitted to the District Authority. The company has been designated as the leader of the neighborhood’s Mutual Aid grouping, established to assist surrounding communities and other industrial entities in responding to an emergency. In addition to providing first responder services in the event of a fire at a neighboring plant, residence or government building, the company has organized in-house seminars and training for other businesses in the area on fire and accident prevention and control techniques. MBIL engages a private company to provide security services at all its plants. Contract provisions include guidelines on how security personnel shall interact with any communities surrounding the plants. MBIL has reviewed PS4 and indicated that it will comply with its requirements in full. In addition to the corporate level contact, the company has designated a contact person at plant level who will be responsible for receiving and responding to questions, concerns or complaints raised by nearby communities or other stakeholders.

Stakeholder Engagement

As noted, MBIL has a history of engagement with the communities in which its plants operate, as well as an explicit policy commitment to corporate social responsibility. In line with this policy, the company prepares annual community development plans in connection with each of its facilities, based on surveys of local communities to identify issues, concerns and specific areas of community life for which improvements are needed. These surveys have identified health and hygiene, general welfare, education and employment levels in the community as the key areas of concern. The company has undertaken a number of projects to address the issues identified by nearby communities, including:

- providing annual medical examinations, carried out by company doctors, to nearby residents;
- setting up an annual “eye camp” which also provide free examinations to residents; and
- supporting activities at local schools near each of its plants.

MBIL has developed a guiding policy document to provide a reference point for employees and stakeholders on the values that drive the conduct of its business and relationships with the world in which it operates. In order to implement Moser Baer’s social responsibility initiatives for the community, the company has formulated “Moser Baer India Trust”, a vehicle to carry out community development programs on behalf of the company. The Trust delivers Community Development services to communities around its strategic locations. As stated in its vision and mission statements, the Trust works for the poorest, underprivileged and vulnerable section of the society and remains committed to achieving Country Development Goals and Millennium Development Goals where it operates.

Key focus areas are evolved after a participatory stakeholder dialogue. Currently, these include health and hygiene, livelihoods and computer education to surrounding communities. Various health and corrective eye surgery camps have been held for poor villagers and local school children and the company runs outpatient clinics as an outreach program. Apart from this, the company also participates in National Health programs such as a polio drive in partnership with the local administration. On a broader level, Moser Baer is represented in the CSR committee of the Confederation of Indian Industry (CII), as well as in an innovative program where its volunteers donate their time and the company its products to create a ‘Talking Book Library’ used by visually challenged people. Senior leaders and Board members of the company are involved as Trustees and members of the CSR committee that guides these programs, and employees contribute regularly to the local communities through special drives like donation of clothes, blood donation camps, and others. Moser Baer employees routinely help with fire fighting measures when needed by the surrounding industries and communities.

During the construction of the PV plant, Moser Baer Trust took up a new initiative to launch a Balwadi centre for children of construction laborers engaged at the new plant site to ensure that they are adequately cared for at the construction site especially when their parents are engaged at work. At present, there are about 67 children between 0-14 years for whom the Balwadi centre ensures protection, care, and meet other needs like education, nutrition and health for their appropriate growth and development. The centre provides the following services:

- pre-school education learning to children between 3-7 years;
- a creche for children below 3 years;
- elementary education to children between 8-14 years;
- nutrition for better physical, mental and cognitive development of all children; and
- general health services to children and the laborer community engaged at the site.

The company’s CSR department also seeks to obtain community feedback on its activities, by meeting with heads of local panchayats and other community groups on a regular basis. As discussed above, the company has designated a contact person within the organization who will be responsible for receiving and responding to questions, concerns or complaints raised by nearby communities or other stakeholders:

Mr. P. K. Singh
Moser Baer India Ltd.
66, Udhyog Vihar
Greater Noida
Telephone: 011- 269 11570 74

The contact details for this individual will be displayed on signage at the entrance to each of the plants.

Client Documentation

File Name	Actions
Final MBPV ESAP.pdf

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

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